App. C: Recovery Planning for CI Belugas

Section 4(f) of the ESA requires NMFS to develop a recovery plan for listed species, unless such a plan will not promote the conservation of the species. On January 28, 2010, NMFS filed a notice of intent to prepare a recovery plan for CI belugas (75 FR 4528).

The Cook Inlet Beluga Whale Recovery Team (CIBRT) was appointed by NMFS’s Alaska Regional Administrator to assist in developing a recovery plan, and to act as an advisory group to identify priority recovery actions and provide input and recommendations on specific recovery issues. NMFS may adopt the team’s draft plan in whole or modify it. Prior to the final approval of any recovery plan, NMFS must provide the public with notice and an opportunity for comment.

The CIBRT was composed of two advisory groups: a Scientific Panel and a Stakeholder Panel. The goal was to produce a science-based plan to foster recovery of the CI beluga. In accordance with national policy, CIBRT members were selected based on their expertise and ability to advance CI beluga recovery.

Given that the ability to effectively manage and recover this population requires an in-depth understanding of the biological and ecological processes of Cook Inlet and the CI beluga, NMFS relied heavily on scientists when developing the recovery plan. The Scientific Panel was composed of beluga experts, scientists, and co-management partners who were appointed as independent experts based upon their specific areas of expertise. Science Panel members did not represent their agency or organization while serving on the panel. The primary functions of the Scientific Panel were to advise NMFS about key scientific data gaps and to draft the recovery plan.

NMFS also recognized there is public interest in CI beluga recovery. For this reason, in addition to utilizing a scientific panel to draft a recovery plan, NMFS invited organizations to be represented on a stakeholder panel to participate in aspects of the recovery planning process. The Stakeholder Panel consisted of representatives of organizations with identified interests in the recovery of CI belugas, or those who may be affected by particular actions taken to recover CI belugas. The function of the Stakeholder Panel was to provide additional information to the Science Panel and NMFS for consideration when drafting the recovery plan. The Stakeholder Panel was also given the opportunity to provide feedback on interim drafts of the recovery plan before the CIBRT submitted its draft plan to NMFS.

The submission of a draft recovery plan to NMFS by the CIBRT in March 2013 culminated a three year process, and represented thousands of hours of volunteer effort from a team comprised of 12 Science Panelists and 19 Stakeholder Panelists. At that time, and with the thanks of NMFS’s Alaska Regional Administrator, the Recovery Team was disbanded and NMFS took responsibility for finalizing the recovery plan.

NMFS reviewed the CIBRT’s draft version of the recovery plan, and made modifications deemed necessary to meet applicable requirements and to ensure a functional plan. Some modifications were minor (e.g., addition of an executive summary and a literature cited section; formatting the document for consistency), whereas other modifications were more substantial. Some of the more substantial modifications included streamlining the background section by moving some of the more detailed, but not necessarily essential, information to the appendices; adding section summaries for the different components of the background section; editing the threats assessment section; and modifying the list of recovery criteria and recovery actions. The modifications to the recovery criteria and recovery actions sections included, for example, a reduction in the redundancy of some criteria/actions; removal of some criteria/actions that did not provide a clear recovery benefit or that required a commitment of resources, authorizations, or continuation of programs that could not be guaranteed; an emphasis on criteria/actions pertaining to threats ranked as medium or high relative concern; a reassessment of some criteria that were not objective or measurable; and a restructuring of the list of recovery actions into a format that helps to focus limited resources on threats that have evidence of limiting the recovery of the CI beluga population. The restructuring of the recovery actions also led to a similar restructuring of the information presented in the implementation table. The intent of these revisions was to make this recovery plan a useful management document for NMFS, while also providing a clear path forward for others to promote the recovery of CI belugas.

NMFS announced the availability of the Draft Recovery Plan for the Cook Inlet Beluga Whale on May 15, 2015, and solicited public comment (80 FR 27925). During the comment period, NMFS received 23 unique public comment submissions from a variety of sources, including conservation groups, industry and industry associations, government agencies, scientists, Alaska Native organizations and tribal members, and interested citizens. NMFS also obtained independent peer review of the draft recovery plan from five reviewers not affiliated with the CIBRT or NMFS. NMFS considered all of the peer review and public comments and information received on the draft recovery plan in developing this final plan. Wherever possible, comments and suggestions were addressed directly as clarifications or refinements to the text. We also made minor updates or added information in this final plan based on scientific references we received or reviewed since the draft recovery plan was released.

Commenters with different interests expressed differing perspectives on certain topics that were in opposition to each other; in particular, they disagreed regarding the emphasis placed on particular threats and related recovery actions. For instance, some industry groups commented that certain threats ranked as medium or high relative concern (e.g., noise, catastrophic events such as oil spills) should not be considered as such until additional scientific data demonstrate those threats are clearly limiting recovery. These commenters also emphasized existing regulations and programs that they considered sufficient to address certain threats. In contrast, conservation groups and some interested citizens argued that a precautionary approach should be taken to address all potential threats until scientific data demonstrates that a particular threat is not limiting recovery. In addition, some of these commenters argued that certain threats ranked as low relative concern, such as pollution, should be ranked higher. Virtually all of the threat types identified in the plan were suggested to be of medium or high relative concern by at least one commenter, but some commenters expressed the view that some threats were ranked too high and should be downgraded. This final plan reflects updates to the background section and analysis of threats to include information submitted by commenters and other references that became available after the draft plan was released. However, after considering the available information, we determined that the comments submitted did not provide a strong basis for changing the assessment of relative concern of potential threats. Therefore, in the final plan we continue to use this threats assessment, which NMFS has determined, based on the best scientific data available, will facilitate addressing threats in a manner likely to lead to recovery of the Cook Inlet beluga.

Given the lack of clear reasons for the failure of CI belugas to recover as expected following a dramatic reduction in subsistence harvest (beginning in 1999), and in an effort to avoid expending limited resources on actions that may have little benefit to the recovery of CI belugas, the plan focuses on addressing threats of medium or high relative concern. To ensure the recovery plan remains strategic, the status of threats ranked as low relative concern will be reassessed periodically to determine if the significance of one or more of those threats has elevated to the point that specified recovery actions need to be defined. The draft plan included recovery actions to improve the understanding and management of a threat, or to eliminate or mitigate the threat, dependent upon evidence strongly suggestive that the threat is limiting CI beluga recovery. In response to comments questioning that provision, we removed the proposed evidentiary requirement for those threat-based recovery actions, and we instead present recovery actions in the final plan based on the best scientific data available. In developing the final plan, we noted that the draft plan contained a number of proposed recovery actions that similarly addressed strandings, public education/outreach activities, and periodic review of the species’ status and threats. To reduce redundancy and simplify the plan, we consolidated the related/overlapping proposed recovery actions for each of these three topics, and included these consolidated actions within an expanded category of recovery actions that address population monitoring, recovery plan implementation, and public education/outreach.

Commenters also expressed differing points of view regarding certain aspects of the recovery criteria proposed in the draft plan, in particular the demographic criteria. While two peer reviewers and a few public commenters questioned the exclusion of population viability analysis (PVA) from the demographic criteria, conversely, the Marine Mammal Commission expressed the view that, given the considerable uncertainty that exists regarding PVA model inputs, basing the criteria on abundance thresholds and trend information is appropriate. Considerable uncertainty remains around some of the PVA model parameters and the existing data, and the sensitivity of the models to rare and unpredictable, but catastrophic events, such as mass strandings. Furthermore, we do not yet understand the parameters that have resulted in the failure of the CI beluga population to exhibit recovery following removal of the most prominent population-limiting threat (unregulated and unsustainable harvest). While we recognize that a better understanding of the factors affecting carrying capacity is also needed, we continue to conclude based on the best scientific data available at this time that demographic recovery criteria based on percent estimated carrying capacity and an abundance trend are more meaningful and effective for this species than the PVA approach. Eventually, as more data become available, a more robust PVA model and more detailed data input could be used to revise the recovery criteria as appropriate. A recovery action is identified in this plan to periodically review, and if appropriate, update a model to determine the probability of extinction of CI belugas, following a schedule that is compatible with the five-year update requirement for NMFS ESA status reviews.

We note that some commenters also questioned defining the current carrying capacity for CI belugas based on the historical abundance estimate of 1,300 whales. As discussed in the plan, this is the best available estimate of historical beluga abundance in Cook Inlet, and represents the maximum estimate of this population based on survey data. Native subsistence harvest (enumerated through hunter interviews) was significant during the 1970s and 1980s and may have been at levels similar to the hunts reported in the mid-1990s, but there was no comprehensive count of subsistence harvest until the 1990s. Commercial and sport hunts also occurred during the 1960s and 1970s, but no information is available to assess whether the 1979 abundance estimate of 1,293 may represent a partially depleted population, and thus a conservative estimate of Cook Inlet carrying capacity for belugas. While we recognize that carrying capacity could change, we have no data at this time to indicate whether carrying capacity may have increased or decreased. Therefore, in the absence of better information, NMFS considers the historical abundance estimate of 1,300 whales to be the carrying capacity of CI belugas.

After considering the comments received along with available data, we also made some minor changes to the threats-based recovery criteria proposed in the draft plan, including: 1) We refined some of the proposed criteria such that they more clearly represent progress toward achieving recovery; 2) We recognized that some of the proposed downlisting criteria represented conditions of a recovered population, so we reclassified those as delisting criteria (e.g., summer range has expanded to reach the documented historical range); and 3) We eliminated a few proposed criteria that we concluded were actions to be taken toward recovery, rather than indicators of recovery (e.g., an outreach program has been implemented that provides voluntary guidelines to reduce/avoid human-caused trauma or harassment of CI belugas).